Last year David Cameron supposedly spearheaded international demands for country-by-country reporting. In 2014 the UK has forgotten that commitment. In the latest edition of Tax Analysts (behind a paywall) Lee Sheppard reports that:
The OECD's recently released draft country-by-country reporting standards are beyond what governments need for transfer pricing risk assessment, Peter Steeds of HM Revenue & Customs said February 10 in London. Action 13 of the OECD base erosion and profit-shifting action plan merely calls for an aerial view of worldwide multinational group structure, he said.
The OECD plan calls for data to be supplied on the most sensitive of group transactions as well as the barest minimum of details that might be termed country-by-country reporting. The intention is obvious; the aim is to identify tax risk at the first possible opportunity, and the UK is objecting to that.
I always suspected that the UK's commitment to country-by-country reporting was at best skin deep since the Treasury has always appeared to side with the tax abuser on this issue. Now we know it is.
Thanks for reading this post.
You can share this post on social media of your choice by clicking these icons:
You can subscribe to this blog's daily email here.
And if you would like to support this blog you can, here:
Here’s some information on Peter Steeds background
“Peter Steeds Head of Transfer Pricing HMRC
Peter Steeds is a Deputy Director in Business International at HMRC responsible for leading the department’s Transfer Pricing work. He chairs HMRC’s Transfer Pricing Board and is a member of the OECD’s Working Party 6 Bureau. Over a 26 year career at HMRC Peter has had extensive experience of working with large business – as a transfer pricing and DTR specialist, as a competent authority and as a Customer Relationship Manager in the pharmaceutical sector.”
Readers can draw their own conclusions.
My thoughts are that his gentleman has placed too much emphasis on his role as “Customer Relationship Manager” and may be responding if not consciously, then unconsciously, to the “requests” made by his major “customers”.
Have you dealt with a CRM? My experience is that they are very accommodating in cutting through red tape, and very hard-nosed when it comes to agreeing the amount of tax due.
Andrew
You know as well as I do there are “clients” and then there are “clients”.
They are not all equal some are more equal than others!
I rather imagine that the multi nationals experience in dealing with their CRMs is rather different from the experience of “Joe the Spark Ltd” in dealing with his CRM.
I doubt very much that JTSL would have his CRM batting on his side as obviously as Mr Steeds does for his “customers”.
Surely you know as well as I do that “Joe the Spark Ltd” doesn’t get a CRM – they’re Large Business Service only. Similar arrangements are being rolled out to non-LBS large businesses, and I hope that one day most businesses will get one, but that’s not the case yet.
In my direct experience of large multinationals (FTSE 100, and blue chip foreign firms), CRMs most definitely are not batting on the company’s side. They’re happy to make a tax manager’s life easy administratively, but they have no interest at all in keeping the tax bill down – quite the reverse.